TEN 18-24 (Accessible PDF).pdf

ETA Advisory File Text

TRAINING AND EMPLOYMENT NOTICE NO. 18-24 DATE December 31 2024 EMPLOYMENT AND TRAINING ADMINISTRATION U.S. DEPARTMENT OF LABOR WASHINGTON D.C. 20210 TO STATE WORKFORCE AGENCIES FROM JOS JAVIER RODR GUEZ Assistant Secretary SUBJECT Customer Experience Checklist and Resources for Unemployment Insurance Programs 1.Purpose. To provide State Workforce Agencies SWAs the customer experience CX checklist which describes principles to improve CX as well as operational experience and outcome metrics and related resources with the goal of helping states to develop a baseline of current practices and identify areas needing improvement in their unemployment insurance UI programs. 2.Action Requested. The U.S. Department of Labor s Department Employment and Training Administration ETA requests that State Administrators provide the information in this Training and Employment Notice TEN to appropriate staff and ETA encourages states to begin utilizing the CX checklist to evaluate their state s UI online systems phone systems and in-person services to improve CX. 3.Summary and Background. a.Summary Effective CX occurs when individuals can effectively and efficiently interact with state UI systems across all access points such as phone website online portal mobile application or in-person. Facilitating effective CX can reduce potential barriers that impact individuals ability to complete required tasks that are associated with UI processes such as submitting an initial claim engaging in fact-finding for adjudication requesting and participating in appeals completing weekly certifications and improper payment reduction and overpayment recovery activities. If CX considerations and improvements are interwoven with a SWA s existing processes then individuals are more likely to complete tasks accurately timely and more independently i.e. requiring fewer SWA staff interactions . Information about CX is most effective when utilized as a tool for continuous improvement with states tracking CX metrics at regular intervals making changes that can address pain points and measuring CX again to see if it has improved. By embracing a customer-centric approach SWAs can achieve Increased level of trust and satisfaction Building confidence and trust by making the UI process easier for claimants employers and agency staff. Reduced administrative burden Streamlining processes and improved self-service options that lead to greater operational efficiency. 2 Strengthened public perception Positive UI experiences contributing to a stronger image of state agencies and the UI system as a whole. Effective CX involves addressing the experience of different stakeholders in the UI processes including but not limited to Individuals interested in learning about and or applying for UI benefits Claimants throughout the claim process Claimant representatives including advocates Employers including third-party administrators TPAs Labor market information staff and other researchers and SWA staff. Providing effective CX contributes to reducing barriers to equitable access that might otherwise negatively impact individuals navigating the UI processes. Effective CX allows claimants and employers to quickly and accurately submit information required helping eligible workers get benefits timely without unnecessary adjudications and appeals and reducing improper payments based on inaccurate information submitted. ETA provides the following additional resources to SWAs as a supplement to this TEN CX Checklist Attachment I Additional Information on Improving Mobile Usability Attachment II and Additional CX References and Resources Attachment III . b. Background The Department has invested over 780 million provided under the American Rescue Plan Act ARPA to help states modernize their UI programs 1 including by improving the claimant experience. Activities funded through this funding included leveraging multidisciplinary teams to identify actions states could take to improve CX see Unemployment Insurance Program Letter UIPL Nos. 02-22 and its subsequent changes and 11-23 providing funds to promote equitable access to unemployment compensation UC programs see UIPL No. 23-21 and its subsequent changes establishing pilot projects to support SWAs in delivering timely benefits to workers especially individuals in groups that are historically underserved marginalized and adversely affected by persistent poverty and inequality see UIPL No. 11-22 and supporting modular and evidence-driven approaches to IT modernization see UIPL No. 11-23 and its subsequent changes . Providing equitable access is an important part leading to an effective CX. The Department issued UIPL No. 01-24 in November 2023 to provide clarity around use of the terms access and equitable access and further describe how program integrity is positively impacted by efforts to ensure equitable access to UC programs. The Department announced publication of an updated UI Equitable Access Toolkit in May 2024 to help states identify and address barriers workers face when seeking UI benefits see TEN No. 30-23 . Additionally the importance of providing effective CX has been mentioned in various Executive Orders to highlight the need that the government must 1 Insights and Successes American Rescue Plan Act Investments in Unemployment Insurance Modernization published November 2023 https www.dol.gov agencies eta ui-modernization arpa-success-stories. 3 ensure its products and services are equitable and effective to communities that have been historically underserved. In April 2024 the Department published a UI Transformation Plan that describes the Department s ongoing and planned efforts to build a more resilient UI system and highlights proposed legislative reforms. 2 Among other things the plan highlights efforts towards improving CX and service delivery as one of seven key action areas to improve the UI program. The oversight community also has an interest in CX and has been monitoring efforts to improve CX at the federal and state levels. For example from 2016 through 2023 the Government Accountability Office issued multiple reports see Attachment III highlighting challenges that impeded CX from the claimants perspective when applying for and receiving UI benefits e.g. insufficient staff inadequate administrative funding and outdated information technology systems . 4. Content. The Department identifies four areas that SWAs are encouraged to focus on for improving CX in their UI programs a Accessibility standards b Principles to improve CX c Baseline CX metrics and d Identifying areas needing improvement. Sections 4.b 4.c and 4.d correspond with the CX checklist in Attachment I to this TEN. In addition to improving CX for individuals applying for UI benefits SWAs should also consider the experience of employers TPAs and internal customers SWA staff . States can leverage the accompanying checklist Attachment I to improve the CX of all customers both internal and external. Using the CX checklist to assess current processes and to drive operational changes will help improve CX in the SWA s UI program. a. Accessibility Standards. When creating content i.e. information resources programs activities digital tools among other items related to accessing navigating and interacting with the UI system SWAs must ensure this content meets Federal accessibility requirements to provide access for people with disabilities including but not limited to visual and hearing impaired limited mobility and limited access including requirements in the Web Content Accessibility Guidelines WCAG 2.1 3 Americans with Disabilities Act ADA see also 29 CFR 38.15 Section 508 of the Rehabilitation Act Section 508 UIPL No. 02-16 and UIPL No. 02-16 Change 1. Building for accessibility means ensuring that the greatest number of people can successfully interact with any UI content to accomplish their end goal. Accessibility Standards mandated by federal regulations must be considered the foundation and minimal baseline when improving CX in state systems. b. Principles to Improve CX Attachment I Section A . The Department identifies six principles to improve CX which expands on the list of principles published in a June 30 2 Building Resilience A Plan for Transforming Unemployment Insurance published April 2024 https oui.doleta.gov unemploy transformation plan.asp. 3 Web Content Accessibility Guidelines https www.w3.org TR WCAG21 . 4 2023 blogpost entitled Customer Experience Principles. 4 Application of these principles can help to increase user satisfaction reduce administrative burden and strengthen public perception. Attachment I to UIPL No. 01-24 describes how states can review each step of the claim cycle or claimant journey for opportunities to improve service delivery. Attachment I to this TEN builds on that resource to provide a checklist for SWAs to evaluate specific areas within their UI system for individuals and employers TPAs whether accessed by phone online or in-person as the state conducts iterative reviews of their systems to strengthen CX. i. Use Plain Language Attachment I Section A.1 . UI programs are complex and this complexity can cause increases in errors in applications and responses to SWAs requests for information. These errors then may result in improper payments overpayments and or underpayments erroneous denials and ultimately increased SWA staff workloads in connection with correcting errors. For this reason it is important that SWAs create UI content initial application forms weekly certification forms notices and web content among other types using plain language. The U.S. General Services Administration provides resources at Plainlanguage.gov and includes a definition of this concept as communication so your audience can understand the first time they read or hear it. Plain language also includes emphasizing actions and next steps as explained below and presenting forms and communications to individuals in their preferred language when possible and or when required by law. To support this effort the Department s UI Equitable Access Toolkit 5 describes Plain Language Standards in Chapter 3. The Department has also published a Language Portfolio 6 with several resources including Plain Language Workshops slides to provide states with technical assistance on plain language content A repository of templates notices and forms that can be customized for each state A UI Lexicon that provides sample meanings for terms commonly used in UI content and A bank of UI application questions based on work with various SWAs and based in plain language principles. 4 Customer Experience Principles https dol.gov agencies eta ui-modernization customer-experience cx-principles. 5 USDOL UI Equitable Access Toolkit https www.workforcegps.org resources 2023 04 UI Content Public Equitable Access Toolkit. 6 USDOL UI Modernization Language Portfolio https www.dol.gov agencies eta ui-modernization language- portfolio. 5 ii. Focus on action instead of information Attachment I Section A.2 . Materials that are poorly written or full of jargon can pose challenges to the reader especially for those with low English literacy limited English proficiency or disabilities. It is important that SWAs ensure that individuals who access the UI system are presented with clear directions on how to apply for benefits and the ongoing requirements to receive benefits if they are found eligible. SWAs can refer to the National Association of State Workforce Agencies NASWA Behavioral Insights BI Toolkit for examples of strategies to implement that focus on actions instead of information in processes such as clarifying work search requirements and reporting earnings and promoting claimant understanding of UI eligibility requirements. 7 When UI communications focus on actions customers must take rather than background on legal requirements they are more likely to produce the desired response. Section 4.c. of this TEN describes methods for states to identify areas for continuous improvement. Establishing robust and ongoing feedback loops with customers is an important way to avoid making assumptions of how users interpret the clarity of a state s instructions. iii. Personalize the content Attachment I Section A.3 . When possible and to the extent allowed by relevant federal and state privacy and disclosure laws use information already on file about a claimant to provide personalized messaging and reminders. SWAs must not include the claimant s full Social Security Number SSN in any personalized messaging. 8 Examples of personalization include addressing form letters to the specific individual by name as well as providing communications to individuals in their preferred language when possible and or when required by law. 9 These CX improvements will increase claimants level of trust and satisfaction. Another effective way to personalize content is implementing reminders. This action can improve CX through informing users of upcoming deadlines that are specific to that individual as well as actions that need to be completed including but not limited to completing weekly certifications attending re-employment workshops responding to requests for information appeal deadlines etc. SWAs may find by implementing reminders that they will receive more responses to requests for information which allows for staff to make more informed decisions when adjudicating issues and potentially resulting in positive impact on improper payment rates. To the extent permissible by state law states should deliver reminders through opt-in SMS messages and or mobile app reminders. This supports claimants who are not regular users of email. SWAs are encouraged to also review the Reminders and Planning Prompts BI Principles in the NASWA BI Toolkit. 7 NASWA BI Toolkit https library.naswa.org bitoolkit. 8 UIPL No. 18-13 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter-no-18-13. 9 For reference see CX principles for online applications https www.dol.gov agencies eta ui-modernization customer-experience improve-applications cx-principles. 6 iv. Proactively and clearly state instructions to support navigation and wayfinding Attachment I Section A.4 . SWAs can reduce calls and office visits from claimants by providing claim status proactively and clearly. As described in Section 4.d.i.D. of UIPL No. 01-24 a status tracker that explains next steps and indicates whether the next step is the responsibility of the state or claimant along with expected agency response times in processing a claim may reduce claimant inquiries and confusion. To support this effort the Department published a Claims Status Playbook 10 that includes a prototype for creating a status tracker considerations for a state interested in starting a claims status project steps to take after identifying objectives and priorities and ways to pursue continuous improvement of processes data notifications and communications. v. Improve mobile usability Attachment I Section A.5 . Mobile usability refers to the ease with which individuals can accomplish tasks on mobile devices such as smartphones or tablets. Mobile usability also encompasses mobile responsiveness which has been mentioned in materials previously published by the Department. 11 Almost 97 percent of Americans own a cell phone and 90 percent own a smart phone furthermore 15 percent of them do not have broadband at home instead depending on their mobile device for Internet usage. 12 A good mobile experience enables people to do the same things they would do on a desktop computer while considering mobile devices constraints. Across different mobile devices the look and feel of an UI application and site may change depending on the screen size but their functionality and usability should remain the same regardless of the screen size operating system data plan or available internet bandwidth. Mobile usability should not be classified as simply good or bad various website functions can range from unusable to very easy to use. For this reason it is important that SWAs design their UI content including websites applications and portals to be responsive and user-friendly on a variety of mobile screen sizes. See Attachment II for more information on specific ways to improve mobile usability. vi. Provide appropriate digital off-ramps Attachment I Section A.6 . Recognizing an existing digital divide between those who have broadband access at home and those who have limited or no access as well as those who do not possess digital literacy to navigate online applications states are required to offer multiple meaningful pathways for individuals to learn about apply and receive UI benefits. UIPL No. 02- 16 and UIPL No. 02-16 Change 1 describe states obligation to provide accessible 10 USDOL Claims Status Playbook https www.dol.gov agencies eta ui-modernization customer- experience claims-status. A webinar describing this tool is also available at https ui.workforcegps.org announcements 2023 09 19 18 29 Claims Status Playbook Webinar 2023. You must be a member of the Workforce GPS UI community to access this event. 11 Improve Mobile Usability https www.dol.gov agencies eta ui-modernization customer-experience mobile- usability. 12 Pew Research Center Mobile Fact Sheet published January 31 2024 https www.pewresearch.org internet fact- sheet mobile . 7 alternatives to web-based technology. States may offer individuals the option of receiving certain information and services via electronic methods but are not permitted to require that individuals communicate only through electronic means. Such policies unduly restrict program access as not all individuals have the ability or capacity to communicate electronically. For persons unable to access or effectively utilize a web-based system the state must offer non-digital alternative options for accessing information and benefits such as by telephone or in person in a manner that ensures effective and meaningful access to the UI system. Digital off-ramps can provide digital and or non-digital alternatives for individuals to easily obtain information and receive assistance when experiencing difficulties in a digital process. Additionally digital off-ramps should provide clear instructions as to next steps when an individual falls out of a digital interaction to improve their confidence trust and stay connected to the UI system. c. Baseline CX Metrics Attachment I Section B . There are three categories of CX metrics the Department is recommending that SWAs use to evaluate the current status of their UI system. While all states are encouraged to use these metrics we especially encourage states that have a grant for IT modernization and or equitable access to benefits through UIPL Nos. 11-23 and 23-21 respectively to carefully review this information as they seek to carry out the requirement to measure the impacts of those grants on customer experience. These metrics can highlight areas demonstrating effective CX areas for improvement and the impact of current practices on internal and external customers. 13 i. Operational metrics also called interaction metrics are centered around transactions and measure specific parts of UI application processes and the UI system. Some examples of what can be measured is how many individuals accessed their online portal in a week how long it takes an individual to complete tasks number of minutes it takes to answer a phone call and more. ii. Experience metrics are based on how the individual felt about their interaction with the state agency and are captured via surveys or questions asked after an in-person online or phone interaction. The answers are typically a scale that ranges from extremely dissatisfied to extremely satisfied with a neutral middle. Some metrics that can be baselined and measured at various intervals are trust satisfaction ease of use timeliness helpfulness of staff interaction etc. It is important to remember that these metrics are completely based on the perception of the individual. iii. Outcome metrics are based on actions completed by individuals and are used to evaluate and determine where improvements can be made in SWAs UI processes. Click-through rates between sections of the UI application number of errors resulting 13 Customer Experience Metrics https www.dol.gov agencies eta ui-modernization customer-experience cx-metrics and Evaluating customer experience with survey design https www.dol.gov agencies eta ui- modernization customer-experience survey-design. 8 at the end and percentage of claimants who do not complete their application or weekly certification abandonment rates are some examples of outcome metrics. d. Identify Areas for Continuous Needing Improvement Attachment I Section C . ETA encourages SWAs to engage in efforts to identify areas in their program operations that need improvement or continuous improvement regarding CX. SWAs are encouraged to i. Conduct direct observations and interviews Attachment I Section C.1 Direct observations produce more accurate results by identifying where individuals encounter confusion with any part of the UI system or its processes. However many individuals choose to interact with the UI system independently without directly engaging with the SWA or its staff. Interviews are a good second choice recruiting participants who have recent experience with the UI program or are about to apply for benefits may result in more accurate findings. SWAs may also develop focus groups including working with community-based organizations claimant advocacy groups and employers or their TPAs to gain feedback into the claimant and employer experiences. Additionally these groups can assist with identifying a diverse group of individuals who traditionally struggle with the UI system such as those with limited digital access limited English proficiency or seasonal workers. Fliers or social media channels can also be used to inform potential participants of the purpose of the interviews. ii. Implement surveys Attachment I Section C.2 SWAs are encouraged to develop and use a simple survey to capture individuals feedback about their experience at points in a customer s experience with the UI program. Surveys should include an open-ended comment field to collect qualitative data about their challenging experiences. Keep the rest of the survey brief ask about one topic per question and use plain language. States can deploy various surveys at different parts of the UI experience Always-on surveys also called persistent Attachment I Section C.2.a to identify chronic challenges these help to identify the areas that need the most improvement and provide a consistent feedback mechanism allowing for long- term monitoring of CX across the UI program. Intercept surveys Attachment I Section C.2.b these surveys are intended to catch attention by popping up at specific points in the claim process. Some examples of potential locations for these surveys are at the end of an application or certification process at common points of abandonment on webpages where the individual has exceeded a pre-determined amount of time etc. Ad-hoc surveys for enhancements and redesigns Attachment I Section C.2.c these are short surveys provided on newly designed or redesigned sections of the UI application or process for a short period of time can help to test the effectiveness of the change. 5. Inquiries. Please direct inquiries to the appropriate ETA Regional Office. 9 6. References. Section 303 of the Social Security Act Section 1137 of the Social Security Act 42 U.S.C. 1320b-7 29 U.S.C. 794d Section 508 of the Rehabilitation Act of 1973 Plain Writing Act of 2010 Pub. L. No. 111-274 codified at 5 U.S.C. 301 note 29 Code of Federal Regulations Part 38 Executive Order 14058 Transforming Federal Customer Experience and Service Delivery To Rebuild Trust in Government issued December 13 2021 https www.federalregister.gov documents 2021 12 16 2021-27380 transforming- federal-customer-experience-and-service-delivery-to-rebuild-trust-in-government Executive Order 13571 Streamlining Service Delivery and Improving Customer Service issued April 27 2011 https www.federalregister.gov documents 2011 05 02 2011-10732 streamlining- service-delivery-and-improving-customer-service Executive Order 12862 Setting Customer Service Standards issued September 11 1993 https www.archives.gov files federal-register executive-orders pdf 12862.pdf UIPL No. 11-23 Change 1 Announcing an Extension of Period of Time that Funding will be Available to Cover Transaction Costs and Announcing the Establishment of a Deadline for States to Enter into Data Sharing Agreements DSAs for the National Identity Verification Offering NIDVO Established in Unemployment Insurance Program Letter UIPL No. 11-23 issued April 29 2024 https www.dol.gov agencies eta advisories uipl-11-23-change-1 UIPL No. 01-24 Equitable Access in the Unemployment Insurance UI Program issued November 8 2023 https www.dol.gov agencies eta advisories uipl-01-24 UIPL No. 11-23 Announcement of Grant Opportunities and National Identity ID Verification Offering under the American Rescue Plan Act ARPA issued July 13 2023 https www.dol.gov agencies eta advisories uipl-11-23 UIPL No. 11-22 Grant Opportunity for States to Participate in the American Rescue Plan Act ARPA Unemployment Insurance UI Navigator Program issued January 31 2022 https www.dol.gov agencies eta advisories unemployment-insurance-program- letter-no-11-22 UIPL No. 02-22 Grant Opportunity to Support States Following a Consultative Assessment for Fraud Detection and Prevention Promoting Equitable Access and Ensuring the Timely Payment of Benefits including Backlog Reduction for all Unemployment Compensation UC Programs issued November 2 2021 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter- no-02-22 UIPL No. 23-21 Grant Opportunity for Promoting Equitable Access to Unemployment Compensation UC Programs issued August 17 2021 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter- no-23-21 10 UIPL No. 02-16 Change 1 State Responsibilities for Ensuring Access to Unemployment Insurance Benefits Services and Information issued May 11 2020 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter- no-02-16-change-1 UIPL No. 02-16 State Responsibilities for Ensuring Access to Unemployment Insurance Benefits issued October 1 2015 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter- no-02-16 UIPL No. 18-13 Rules for the Appropriate Use of and Access to Social Security Numbers issued May 24 2013 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter- no-18-13 UIPL No. 21-05 Use of Identifying Information on Unemployment Insurance UI Documents issued April 18 2005 https www.dol.gov agencies eta advisories unemployment-insurance-program-letter- no-21-05 and TEN No. 30-23 Availability of the Unemployment Insurance UI Equitable Access Toolkit May 8 2024 https www.dol.gov agencies eta advisories ten-30-23. 7. Attachment s . Attachment I Customer Experience CX Checklist. Attachment II Additional Information on Improving Mobile Usability. Attachment III Customer Experience CX Additional References and Resources.